15 October 1990 Ruling 902473 F - Rights to Purchase Shares Excluded as Taxable Benefits

By services, 18 January, 2022
Official title
Rights to Purchase Shares Excluded as Taxable Benefits
Language
French
CRA tags
15(1)(c)
Document number
Citation name
902473
Severed letter type
Ruling
d7 import status
Drupal 7 entity type
Node
Drupal 7 entity ID
629818
Extra import data
{
"field_external_guid": [],
"field_proprietary_citation": [],
"field_release_date_new": "1990-10-15 08:00:00",
"field_tags": []
}
Main text
24(1) 902473
  L.A. McCarron-McGuire
  (613) 957-2092
19(1)

October 15, 1990

Dear Sirs:

Re:  Request for Technical Interpretation Paragraph 15(1)(c) of the Income Tax Act (Canada) (the "Act")

This letter is in response to yours of September 14, 1990 wherein you asked for our confirmation that the exception contained in paragraph 15(1)(c) of the Act will apply in the following situation:

     A corporation confers on all owners of common shares of the capital stock of the corporation a right to buy a unit, the unit consisting of a common share and a warrant (or a fraction of a warrant) to purchase a common share.

It is our view that the exception in paragraph 15(1)(c) of the Act would apply to the right to acquire such a unit.

The foregoing expression of opinion is given in accordance with the practice referred to in paragraph 21 of Information Circular 70-6R2 dated September 28, 1990, and is not binding on Revenue Canada, Taxation.

Yours truly,

for DirectorReorganizations and Non-resident DivisionRulings DirectorateLegislative and Intergovernmental Affairs Branch